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E.D. Pa. · Judge Perez · Practice Guide

Hon. Mia Roberts Perez

All local rules for E.D. Pa., integrated with this judge's published requirements.

Know Before You Go
👤 Judge Perez — deviations that burn people
  • 1. Motion + brief combo cannot exceed 20 pages (opposition same limit) -- there is no separate opposition limit, so a 25-page opposition violates the rule.
  • 2. Rule 12 motions require a meet-and-confer at least 7 days before filing; no certification = motion denied.
  • 3. Summary judgment SUMF process is entirely pre-filing: moving party serves SUMF 28 days before deadline, response served 14 days before deadline -- nothing filed on the docket until the consolidated statement is filed with the motion.
  • 4. Trial pool cases must be ready to start on 48-hours notice; requests to extend trial must be in writing to Chambers 30 days in advance.
  • 5. Third-party litigation funding must be disclosed (beyond Rule 7.1) -- an easy trap for funded plaintiffs who overlook this additional requirement.
Get updates when Judge Perez's procedures change
Discovery Motions
Who decides discovery disputes in this judge's cases: the judge themself, a referral to a magistrate (always / usually / case-by-case), or a special master?
🏛 E.D. Pa. local rule

In accordance with procedures adopted by the Board of Judges, each district judge shall have an assigned magistrate judge. (p. 50)

Matters shall be referred to magistrate judges at the direction of the district judge to whom the case is assigned. (p. 50)

Local R. Civ. P. 72.1(II)

👤 Judge Perez — standing order

Nothing posted.

Pre-motion conferral: required? Format (in person / live / written OK)? Who arranges it, deadline, number of attempts?
🏛 E.D. Pa. local rule

No motion or other application pursuant to the Federal Rules of Civil Procedure governing discovery or pursuant to this rule shall be made unless it contains a certification of counsel that the parties, after reasonable effort, are unable to resolve the dispute. (p. 30)

Local R. Civ. P. 26.1(f)

👤 Judge Perez — standing order

Nothing posted.

What proof of conferral must be filed or stated (certification, letter, dates, participants, duration)?
🏛 E.D. Pa. local rule

it contains a certification of counsel that the parties, after reasonable effort, are unable to resolve the dispute. (p. 30)

Local R. Civ. P. 26.1(f)

👤 Judge Perez — standing order

Nothing posted.

Must (or may) the parties get a conference with the court before a written motion (IDC, pre-motion conference, discovery hotline, teleconference)? Required / optional / not offered?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Perez — standing order

“Communications with Chambers Judge Perez permits communications with Chambers by telephone or email regarding scheduling and other non-substantive matters.” · Policies and Procedures

“All other issues must be addressed by motion or other filing.” · Policies and Procedures

The vehicle and contents for raising a dispute with the court: letter / letter-motion / email / form / joint submission. Joint or unilateral? Page or word limits, required contents, attachments.
🏛 E.D. Pa. local rule

Every motion pursuant to the Federal Rules of Civil Procedure governing discovery (p. 29)

Local R. Civ. P. 26.1(b)

👤 Judge Perez — standing order

“All other issues must be addressed by motion or other filing.” · Policies and Procedures

If a written motion is filed: form (joint stipulation, standard motion, letter brief), length, required contents (e.g., verbatim requests and responses), briefing schedule
🏛 E.D. Pa. local rule

Every motion pursuant to the Federal Rules of Civil Procedure governing discovery shall identify and provide, verbatim, the relevant parts of the interrogatory, request, answer, response, objection, notice, subpoena, or depositions in the party’s memorandum. (p. 29)

Counsel may also identify the disputed discovery in an attached exhibit, provided that the exhibit clearly identifies the relevant portions. (p. 29)

Any party responding to the motion shall provide, verbatim, any other part that the party believes necessary to the court's consideration of the motion. (p. 29)

A routine motion to compel answers to interrogatories or to compel compliance with a request for production under Federal Rule of Civil Procedure 34, wherein it is averred that no response or objection has been timely served, need have no accompanying brief, and need have no copy of the interrogatories or Federal Rule of Civil Procedure 34 request attached. (p. 30)

Every motion shall be accompanied by a form of order which, if approved by the court, would grant the relief sought by the motion. (p. 18)

Every motion not certified as uncontested, or not governed by Local Civil Rule 26.1(g), shall be accompanied by a brief containing a concise statement of the legal contentions and authorities relied upon in support of the motion. (p. 18)

Unless the Court directs otherwise, any party opposing the motion shall serve a brief in opposition together with such answer or other response that may be appropriate, within fourteen (14) days after service of the motion and supporting brief. (p. 18)

Counsel are directed to consult each judge’s policies and procedures. (p. 18)

Local R. Civ. P. 26.1(b), 26.1(g), 7.1(a), 7.1(c)

👤 Judge Perez — standing order

“Any motion and its supporting memorandum of law, as well as opposition briefs, shall not total more than 20 pages.” · Policies and Procedures

“In those rare instances in which counsel believes additional pages are necessary, counsel should seek leave to exceed the page limit by motion.” · Policies and Procedures

Replies, supplemental memos, sur-replies: allowed? Limits?
🏛 E.D. Pa. local rule

The Court may require or permit additional briefs or submissions if the Court deems them necessary. (p. 18)

Local R. Civ. P. 7.1(c)

👤 Judge Perez — standing order

“Reply briefs in support of a dispositive motion may be submitted without leave of Court.” · Policies and Procedures

“Replies must be responsive to arguments raised by opposing counsel and shall not exceed 7 pages.” · Policies and Procedures

“A sur-reply may only be filed with permission of the Court upon good cause shown and may not exceed 5 pages.” · Policies and Procedures

“Replies and sur-replies must be filed no later than 7 days after the filing to which it responds, but Judge Perez reserves the right to rule on the motion in the interim.” · Policies and Procedures

Must disputes be filed / heard / decided before the discovery cutoff? Any lead-time requirement?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Perez — standing order

Nothing posted.

Is there a hearing? When, how (in person / phone / video), decided on papers?
🏛 E.D. Pa. local rule

Any interested party may request oral argument on a motion. The court may dispose of a motion without oral argument. (p. 18)

Local R. Civ. P. 7.1(f)

👤 Judge Perez — standing order

“Oral argument will be scheduled as needed by the Courtroom Deputy.” · Policies and Procedures

Emergency / ex parte discovery relief (e.g., disputes during a deposition): allowed? How?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Perez — standing order

Nothing posted.

Stated consequences for not following the procedure
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Perez — standing order

Nothing posted.

Hearings & Calendar
When does the judge hear civil motions?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Perez — standing order

Nothing posted.

How do you get a hearing date? Self-notice on the motion day, reserve with the courtroom deputy first, or the court sets it? Notice period? Closed dates?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Perez — standing order

“Communications with Chambers Judge Perez permits communications with Chambers by telephone or email regarding scheduling and other non-substantive matters.” · Policies and Procedures

“In civil cases, all motions should be filed in compliance with the Scheduling Order.” · Policies and Procedures

“Oral argument will be scheduled as needed by the Courtroom Deputy.” · Policies and Procedures

Is there oral argument by default, or is it decided on the papers? Can the court vacate the hearing?
🏛 E.D. Pa. local rule

The court may dispose of a motion without oral argument. (p. 18)

Local R. Civ. P. 7.1(f)

👤 Judge Perez — standing order

“Oral argument will be scheduled as needed by the Courtroom Deputy.” · Policies and Procedures

How do you request oral argument (or a hearing) if it isn't automatic?
🏛 E.D. Pa. local rule

Any interested party may request oral argument on a motion. (p. 18)

Local R. Civ. P. 7.1(f)

👤 Judge Perez — standing order

Nothing posted.

Does the judge issue tentative rulings? When and where are they posted, and what do you do if you submit on one?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Perez — standing order

Nothing posted.

Can you appear remotely (phone/video)? How and when to request it?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Perez — standing order

“All conferences will be held in person in Judge Perez's Chambers.” · Policies and Procedures

Does the judge encourage or guarantee argument by newer attorneys?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Perez — standing order

Nothing posted.

How do you continue/adjourn a hearing?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Perez — standing order

Nothing posted.

Courtroom technology and devices: equipment available; phones/laptops allowed; testing in advance
🏛 E.D. Pa. local rule

No judicial proceedings may be broadcast by radio or television, or filmed by still or motion-picture camera or other electronic device, (p. 52)

Except as provided by any applicable standing court order concerning electronic devices, no cameras, broadcasting mechanisms, or electronic device capable of filming or recording may be brought into, or retained or operated within, any district court courtroom or any hall on the same floor as such courtroom. (p. 52)

Local R. Civ. P. 83.3(a), (b)

👤 Judge Perez — standing order

Nothing posted.

Stated consequences for hearing-related noncompliance
🏛 E.D. Pa. local rule

No attorney shall, without just cause, fail to appear when that attorney's case is before the court on a call, motion, pretrial proceeding, or trial, (p. 66)

Any attorney who fails to comply with (a) or (b) may be disciplined as the court shall deem just. (p. 66)

Local R. Civ. P. 83.6.1(b), (c)

👤 Judge Perez — standing order

Nothing posted.

Summary Judgment
How many SJ motions may each party (or side) file, and how do you get leave for more?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Perez — standing order

Nothing posted.

What page limits apply to SJ briefs, where they differ from the general motion limits?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Perez — standing order

“Reply briefs in support of a dispositive motion may be submitted without leave of Court.” · Policies and Procedures

“Replies must be responsive to arguments raised by opposing counsel and shall not exceed 7 pages.” · Policies and Procedures

“A sur-reply may only be filed with permission of the Court upon good cause shown and may not exceed 5 pages.” · Policies and Procedures

Do you need the court's permission, a pre-motion conference or letter, a status report, or advance notice before filing?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Perez — standing order

“Judge Perez permits communications with Chambers by telephone or email regarding scheduling and other non-substantive matters.” · Policies and Procedures

“All other issues must be addressed by motion or other filing.” · Policies and Procedures

Can you move for SJ before discovery closes?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Perez — standing order

Nothing posted.

When must the motion be filed or heard, and on what briefing schedule?
🏛 E.D. Pa. local rule

Unless the Court directs otherwise, any party opposing the motion shall serve a brief in opposition together with such answer or other response that may be appropriate, within fourteen (14) days after service of the motion and supporting brief. (p. 18)

Local Civ. R. 7.1(c)

👤 Judge Perez — standing order

Nothing posted.

Before filing, must the movant confer with or serve SJ papers on the opponent, and how far ahead?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Perez — standing order

“At least 28 days before the deadline to file a motion, the moving party must serve all other parties a statement of undisputed facts in a numbered, paragraph-by-paragraph statement that contains specific citations to the record that support each factual assertion.” · Policies and Procedures

“At least 14 days before the deadline to file a motion, a responding party must serve on all other parties, a response to the moving party's statement of facts that responds to each factual assertion.” · Policies and Procedures

“The moving party may then respond to any statement or arguments in the responding party's submission, directly under the paragraph in question.” · Policies and Procedures

“This process of serving and responding should not be filed with the Court on the docket but must be realized with all other parties.” · Policies and Procedures

What kind of fact statement does the judge want?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Perez — standing order

“All summary judgment motions must be accompanied by a statement of facts that the parties will prepare jointly and that must be separately filed on the docket.” · Policies and Procedures

“The final product of this process should result in a single statement of facts with detailed paragraphs where an opposing party is responding in agreement with a factual assertion or questioning the factual assertion, allowing Judge Perez to see each party's position on each factual assertion.” · Policies and Procedures

“If there are cross-motions for summary judgment, each movant may file a statement of facts that follows the above guidelines.” · Policies and Procedures

Is there a cap on the fact statement (and the response)?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Perez — standing order

Nothing posted.

How must the fact statement and responses be laid out?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Perez — standing order

“At least 28 days before the deadline to file a motion, the moving party must serve all other parties a statement of undisputed facts in a numbered, paragraph-by-paragraph statement that contains specific citations to the record that support each factual assertion.” · Policies and Procedures

“All responses should be directly under the original paragraph of the moving party's motion and must include citations to any evidence that the responding party believes is necessary to show that the moving party has not cited evidence that supports a factual assertion.” · Policies and Procedures

“The moving party may then respond to any statement or arguments in the responding party's submission, directly under the paragraph in question.” · Policies and Procedures

“The final product of this process should result in a single statement of facts with detailed paragraphs where an opposing party is responding in agreement with a factual assertion or questioning the factual assertion, allowing Judge Perez to see each party's position on each factual assertion.” · Policies and Procedures

How do you raise evidentiary objections to the other side's SJ evidence?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Perez — standing order

Nothing posted.

How must SJ evidence be assembled?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Perez — standing order

“All parties must attach a joint list of all exhibits referenced in the statement of facts, in addition to an index of the exhibits.” · Policies and Procedures

“If there are cross-motions for summary judgment, each movant may file a statement of facts that follows the above guidelines.” · Policies and Procedures

“However, there must be a single, consolidated set of exhibits.” · Policies and Procedures

Do you file full deposition transcripts or only the cited excerpts?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Perez — standing order

Nothing posted.

In the brief, do you cite the record, the fact statement, or both? Must the brief carry its own statement of facts?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Perez — standing order

Nothing posted.

If the motion or opposition depends on excluding an expert, how and when must the challenge be raised?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Perez — standing order

Nothing posted.

How are cross-motions handled?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Perez — standing order

“If there are cross-motions for summary judgment, each movant may file a statement of facts that follows the above guidelines.” · Policies and Procedures

“However, there must be a single, consolidated set of exhibits.” · Policies and Procedures

Will the judge entertain SJ in a non-jury case?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Perez — standing order

Nothing posted.

What consequences does the judge's own text state for SJ noncompliance?
🏛 E.D. Pa. local rule

In the absence of a timely response, the motion may be granted as uncontested except as provided under Federal Rule of Civil Procedure 56, or otherwise prohibited by law. (p. 18)

Local Civ. R. 7.1(c)

👤 Judge Perez — standing order

Nothing posted.

Pro Hac Vice
What does PHV admission cost, who pays it, and is it ever waived?
🏛 E.D. Pa. local rule

No admission shall be effective until such time as the fee has been paid, except that any counsel appearing in a case transferred pursuant to an Order of the Judicial Panel on Multidistrict Litigation need not pay such a fee. (p. 56)

Standing Order (Feb. 13, 2023); LCvR 83.5.2(b); form

👤 Judge Perez — standing order

Nothing posted.

Must PHV counsel associate with local counsel (a member of this court's bar), and who qualifies?
🏛 E.D. Pa. local rule

(a) Except for attorneys appearing on behalf of the United States Government or a department or agency thereof pursuant to Local Civil Rule 83.5(e), any attorney who is not a member of the bar of this court shall, in each proceeding in which that attorney desires to appear, have as associate counsel of record a member of the bar of this court upon whom all pleadings, motions, notices and other papers can be served conformably to the Federal Rules of Civil Procedure and the local rules of this court. (p. 56)

LCvR 83.5.2(a)

👤 Judge Perez — standing order

Nothing posted.

Who files the PHV motion or application: the applicant, or local or sponsoring counsel?
🏛 E.D. Pa. local rule

(b) An attorney who is not a member of the bar of this Court shall not actively participate in the conduct of any trial or pre-trial or post-trial proceeding before this Court unless, upon motion of a member of the bar of this Court containing a verified application, leave to do so shall have been granted. (p. 56)

LCvR 83.5.2(b)

👤 Judge Perez — standing order

Nothing posted.

What proof of good standing is required (a certificate or a sworn statement), from which bars, and how recent?
🏛 E.D. Pa. local rule

C. I state that I am at present a member of the aforesaid bar(s) in good standing, and that I will demean myself as an attorney of this court uprightly and according to law, and that I will support and defend the Constitution of the United States. (p. 2)

The undersigned member of the bar of the United States District Court for the Eastern District of Pennsylvania hereby moves for the admission of _______________________________________________ to practice in said court pursuant to Local Rule of Civil Procedure 83.5.2(b), and certify that I know (or after reasonable inquiry believe) that the applicant is a member in good standing of the above-referenced state and federal court(s) and that the applicant's private and personal character is good. (p. 3)

Court form

👤 Judge Perez — standing order

Nothing posted.

What must the PHV motion or application contain, and must (or may not) a particular form be used?
🏛 E.D. Pa. local rule

(b) An attorney who is not a member of the bar of this Court shall not actively participate in the conduct of any trial or pre-trial or post-trial proceeding before this Court unless, upon motion of a member of the bar of this Court containing a verified application, leave to do so shall have been granted. (p. 56)

LCvR 83.5.2(b); court form

👤 Judge Perez — standing order

“Motions for pro hac vice admission must be made using the Eastern District of Pennsylvania's form; this is available on the Court's website:” · Policies and Procedures

By when must the PHV motion be filed or granted: before a filing, before a conference, or at the first appearance? Is an oral motion allowed?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Perez — standing order

Nothing posted.

Must PHV counsel register for ECF (or is it barred), and by when?
🏛 E.D. Pa. local rule

________________ is DIRECTED to request ECF filing access using their PACER Account1. (p. 1)

Court form (proposed order)

👤 Judge Perez — standing order

Nothing posted.

What must local counsel do once PHV counsel is in the case (attend conferences or hearings, sign filings, know the case, accept service, answer for PHV counsel)?
🏛 E.D. Pa. local rule

At least one associate counsel shall maintain their appearance on the docket until the conclusion of the case or until granted leave to withdraw by the court. (p. 56)

(a) Except for attorneys appearing on behalf of the United States Government or a department or agency thereof pursuant to Local Civil Rule 83.5(e), any attorney who is not a member of the bar of this court shall, in each proceeding in which that attorney desires to appear, have as associate counsel of record a member of the bar of this court upon whom all pleadings, motions, notices and other papers can be served conformably to the Federal Rules of Civil Procedure and the local rules of this court. (p. 56)

LCvR 83.5.2(a)-(b)

👤 Judge Perez — standing order

“Sponsoring counsel and other associated members of the bar of the Eastern District of Pennsylvania are responsible for the conduct of pro hac vice co-counsel and for the integrity of all representations to the Court.” · Policies and Procedures

“Absent leave, the presence of at least one member of the bar of the Eastern District of Pennsylvania is required at hearings and trials.” · Policies and Procedures

Must the PHV motion state the other parties' position or consent, or confer with them first? When may the other side oppose?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Perez — standing order

Nothing posted.

What consequences does the judge's own text state for PHV problems (revocation of PHV status, denial, a duty to bring in local counsel)?
🏛 E.D. Pa. local rule

No admission shall be effective until such time as the fee has been paid, except that any counsel appearing in a case transferred pursuant to an Order of the Judicial Panel on Multidistrict Litigation need not pay such a fee. (p. 56)

LCvR 83.5.2(b)

👤 Judge Perez — standing order

Nothing posted.

Are attorneys who live, work, or are barred in this state excluded from PHV and sent to full admission?
🏛 E.D. Pa. local rule

I, _________________________________________ the undersigned, am an attorney who is not currently admitted to either the bar of this court or the bar of the Supreme Court of Pennsylvania, and I hereby apply for admission to practice in this court pursuant to Local Rule of Civil Procedure 83.5.2(b) to represent ________________________. (p. 2)

Standing Order (Feb. 13, 2023); court form

👤 Judge Perez — standing order

Nothing posted.

Is there a cap on how often an attorney may appear PHV, or a required disclosure of past PHV applications?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Perez — standing order

Nothing posted.

Do government attorneys need PHV admission, and are they exempt from the fee or local counsel?
🏛 E.D. Pa. local rule

(e) Any attorney who is a member in good standing of the bar of the highest court of any state, territory, or the District of Columbia may, without being admitted generally as an attorney of this Court, act as an attorney in this Court on behalf of the United States Government or any of its departments or agencies. (p. 53)

LCvR 83.5(e); 83.5.2(a)

👤 Judge Perez — standing order

Nothing posted.

Other procedures for Judge Perez
Before You File
Contacting chambers
👤 Judge Perez — standing order

Judge Perez permits communications with Chambers by telephone or email regarding scheduling and other non-substantive matters. All other issues must be addressed by motion or other filing. Under no circumstances may any party or counsel communicate ex parte with any Chambers personnel concerning substantive matters. Inquiries should be directed to Judge Perez's Courtroom Deputy. If the Deputy is not available, then Judge Perez permits counsel to speak with her Judicial Assistant. If necessary, attorneys may speak to Judge Perez's law clerks regarding scheduling matters; however, law clerks may not render advice to counsel.

Drafting the Motion
Length limits — motion, opposition, reply
🏛 E.D. Pa. local rule
Opposition

Silent on page limits for opposition briefs. E.D. Pa. L.R. 7.1 (silent) ↗

Reply

Silent on page limits for reply briefs. E.D. Pa. L.R. 7.1 (silent) ↗

👤 Judge Perez — standing order
Opposition

Any motion and its supporting memorandum of law, as well as opposition briefs, shall not total more than 20 pages.

Reply

Reply briefs in support of a dispositive motion may be submitted without leave of Court. Replies must be responsive to arguments raised by opposing counsel and shall not exceed 7 pages. A sur-reply may only be filed with permission of the Court upon good cause shown and may not exceed 5 pages. Replies and sur-replies must be filed no later than 7 days after the filing to which it responds, but Judge Perez reserves the right to rule on the motion in the interim.

Filing & Scheduling
Proposed orders
🏛 E.D. Pa. local rule

(a) Every motion shall be accompanied by a form of order which, if approved by the court, would grant the relief sought by the motion. Every response in opposition to a motion shall be accompanied by a form of order, which, if approved by the court, will deny or amend the relief sought by the motion. E.D. Pa. L.R. 7.1(a) ↗

More from Judge Perez’s procedures
👤 Judge Perez — standing order
Summary judgment procedure

All summary judgment motions must be accompanied by a statement of facts that the parties will prepare jointly and that must be separately filed on the docket. All parties must attach a joint list of all exhibits referenced in the statement of facts, in addition to an index of the exhibits. The Parties should prepare the statement of facts in accordance with the following guidelines: 1. At least 28 days before the deadline to file a motion, the moving party must serve all other parties a statement of undisputed facts in a numbered, paragraph-by-paragraph statement that contains specific citations to the record that support each factual assertion. 2. At least 14 days before the deadline to file a motion, a responding party must serve on all other parties, a response to the moving party's statement of facts that responds to each factual assertion. All responses should be directly under the original paragraph of the moving party's motion and must include citations to any evidence that the responding party believes is necessary to show that the moving party has not cited evidence that supports a factual assertion. 3. The moving party may then respond to any statement or arguments in the responding party's submission, directly under the paragraph in question. The final product of this process should result in a single statement of facts with detailed paragraphs where an opposing party is responding in agreement with a factual assertion or questioning the factual assertion, allowing Judge Perez to see each party's position on each factual assertion. If there are cross-motions for summary judgment, each movant may file a statement of facts that follows the above guidelines. However, there must be a single, consolidated set of exhibits. This process of serving and responding should not be filed with the Court on the docket but must be realized with all other parties. Source ↗

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